The modern payments ecosystem is undergoing a seismic shift. The implementation of the new Instant Payments Regulation (Regulation (EU) 2024/886) impacts Payment Service Providers (“PSPs”) that offer credit transfers in the European Union including:
- Credit Institutions,
- Electronic Money Institutions (EMIs),
- Payment Institutions (PIs), and,
- Central Banks (when not acting in their capacity as monetary authorities).
The Instant Payments Regulation is a comprehensive legislative framework designed to modernise the Single Euro Payments Area (SEPA). It aims to ensure that credit transfers are executed almost instantaneously, within a 10-second window from initiation to funds availability. This breakthrough transforms long-standing payment practices by replacing traditional processes with streamlined, real-time systems. To facilitate a phased and systematic integration, the Regulation sets strict deadlines:
By January 9, 2025: PSPs (excluding PIs and EMIs, thus, effectively, Credit Institutions and Central Banks) had to deploy the necessary infrastructure to receive instant credit transfers in the eurozone.
By October 9, 2025: Credit Institutions and Central Banks are required to have the operational capability to send instant credit transfers in the eurozone.
By January 9, 2027: Credit Institutions and Central Banks located in a Member State whose currency is not the Euro must deploy the necessary infrastructure to receive instant credit transfers in Euro.
By April 9, 2027: PSPs that are EMIs or PIs located in a Member State, regardless of national currency must deploy the necessary infrastructure to receive instant credit transfers in Euro. Additionally, EMIs and PIs located in the eurozone need to be able to send instant credit transfers.
By July 9, 2027: EMIs and PIs located in a Member State whose currency is not the Euro must deploy the necessary infrastructure to send instant credit transfers in Euro.
By June 9, 2028: PSPs located in a Member State not in the eurozone must be able to send instant credit transfers in Euro outside business hours.
Security is a crucial aspect of this new framework given the rapid nature of transactions. The regulation enforces stringent security protocols, including the Verification of Payee (VoP) process, which mandates the immediate validation of customer identities and account details at the point of transaction initiation. Furthermore, systems must be continuously updated to screen and monitor for AML/CFT, Fraud, and Sanctions. It is important to understand what the effects of this new regulation on AML/CFT processes are for banks and other PSPs.
CDD/KYC Processes
Customer Due Diligence (CDD) and Know Your Customer (KYC) remain crucial for financial compliance. However, the rise of instant payments has exposed the bottlenecks of traditional, manual verification. For example, the Verification of Payee (VoP) demands an immediate cross-check of customer data against trusted records. As such, legacy KYC systems designed for slower manual reviews must evolve. They need to be replaced or upgraded to support automated, real-time assessments powered by artificial intelligence and machine learning. These advanced technologies rapidly analyse data to assess risk, verify documents, and continuously update customer profiles, especially when combined with government-issued e-ID systems and third-party verification platforms. This shift also calls for a strategic and operational overhaul. Integrating real-time CDD/KYC into payment flows transforms compliance from periodic reviews to continuous monitoring and dynamic risk profiling. Achieving this requires recalibrated workflows, retrained staff, and strong investments in technology and personnel to build a responsive compliance infrastructure.
Transaction Monitoring
Instant payments demand a revolution of transaction monitoring methods. Instead of relying mostly on post-transaction reviews, PSPs must further invest on continuous, real-time scrutiny. Transactions should be evaluated using, for example, advanced data streaming and processing technologies that can handle high volumes simultaneously. This immediate analysis relies on sophisticated AI-driven algorithms that process vast datasets and incorporate anomaly detection techniques from both historical and real-time data, ensuring that genuine risks are accurately flagged. Regulatory compliance further requires that monitoring activity is meticulously logged. Continuous record-keeping allows every transaction to be traced, and all anomalies documented for later audits, supporting both immediate interventions and building trust with regulators and customers. Moreover, when suspicious activities are detected, monitoring systems must integrate seamlessly with forensic investigation tools. This integration enables compliance teams to swiftly analyse flagged transactions, trace their origins, and implement corrective actions promptly.
Sanctions Screening and Fraud Detection
Traditional sanctions screening involved detailed, transaction-by-transaction verification to comply with various regulatory, national, and international restrictions. With modern regulations and the impracticality of real-time checks in a 10-second window, institutions must now orient their sanction screening towards customers, instead of transactions. This approach relies on updating customer and transaction data daily, or even more frequently, while linking systems to centralised, continuously updated sanctions databases so that any change in sanctioned entities is immediately reflected.
In parallel, compliance modernisation has spurred advanced fraud detection. As near-instant payments and cross-border transactions become routine, the risk of fraudulent activity increases. PSPs must deploy sophisticated analytics and behavioural monitoring to identify anomalies and unusual transaction patterns in real time. The combination of automated sanctions screening and proactive fraud detection creates a robust defence that protects both customers and the institution from emerging digital threats.
Managing Client Expectations vs AML/CFT Obligations
PSPs today face the challenge of meeting customer demands for fast, seamless transactions while adhering to strict AML/CFT regulations. Even though clients expect instant processing, essential measures such as real-time identity verification, continuous transaction monitoring, and regular sanctions checks may slow things down. Transparent communication about these safeguards not only helps customers understand the necessary delays but also builds trust by highlighting the security behind every transaction. Integrating user-friendly digital technologies, like efficient identity verification systems and clear status updates, helps demystify the process, ensuring that robust AML/CFT controls operate in the background without compromising speed. Ultimately, a balanced approach relies on strategic investments in both advanced technology and process enhancements, ensuring that rapid transactions and stringent compliance work together to foster long-term customer confidence.
Conclusion
The Instant Payments Regulation stands as a transformative force reshaping the very fabric of financial operations. It is not merely about accelerating fund transfers; it is about overhauling legacy systems, redefining risk management methodologies, and integrating cutting-edge technology to meet the evolving demands of AML/CFT compliance. PSPs are now tasked with implementing systems that guarantee real-time risk assessments while delivering a frictionless customer experience. This dual imperative, seamless service and uncompromised security, drives continuous innovation in areas such as automated CDD/KYC processes, dynamic transaction monitoring, and modernised sanctions screening.
This article was co-authored by Luis Pereira, Deborah Cassar, and Alex Azzopardi from our Risk Consulting Advisory Services Team.
